XL HEALTH CORPORATION INDIA PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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ITA 420/BANG/2022Status: DisposedITAT Bangalore24 April 2025AY 2017-18Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER IT(TP)A Nos.420 & 902/Bang/2022 Assessment years : 2017-18 & 2018-19 | XL Health Corporation India Pvt. Ltd., No.54, Abacus Centre, I Main, Sarakki Industrial Area, III Phase, Bengaluru – 560 078. PAN: AAACX 0544K APPELLANT | Vs. | The Assistant Commissioner of Income Tax, Circle 7(1)(1), Bengaluru. RESPONDENT | |---|---|---| | Appellant by | : | Shri Prathik Rath, Advocate | |---|---|---| | Respondent by | 2 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The assessee informed the Tribunal that it had received and accepted a Mutual Agreement Procedure (MAP) resolution for the assessment years in question. Consequently, the assessee requested to withdraw its appeals, which the DR agreed to. The Tribunal dismissed the appeals as withdrawn.

What were the facts?

XL Health Corporation India Pvt. Ltd. filed two appeals against final assessment orders for AYs 2017-18 and 2018-19. These orders were passed under Sections 143(3), 144C(13), and 144B of the Income-tax Act, 1961, following orders from the Dispute Resolution Panel.

What were the issues?

Whether the appeals should be dismissed as withdrawn given the assessee's acceptance of a Mutual Agreement Procedure (MAP) resolution.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI PRAKASH CHAND YADAV

For Appellant: Shri Prathik Rath, Advocate
For Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Hearing: 04.04.2025Pronounced: 24.04.2025

Per Prashant Maharishi, Vice President 1. These two appeals are filed by XL Health Corporation India Pvt. Ltd. (the assessee/appellant) against the final assessment orders passed by the Assessing Officer, National Faceless Assessment Centre, Delhi (NFAC) / Assessment Unit, Income Tax Department [ld. AO] u/s. 143(3) r.w.s. 144C(13) r.w.s. 144B of the Income-tax Act, 1961 [the Act] dated 31.03.2022 & 29.7.2022 for the assessment years 2017-18 & 2018-19

1.

IT(TP)A No.420/Bang/2024 Page 2 of 2 in pursuance of the ld. Dispute Resolution Panel’s (DRP) order dated 27.01.2022 & 14.6.2022 respectively.

2.

At the outset, the ld. counsel for the assessee invited attention to the assessee’s letter dated 13.1.2025 stating that the assessee has received MAP resolution agreed upon by the competent authorities in accordance with Rule 44G(6) of the Income-tax Rules, 1962 for AY 2017-18 and 2018-19 and assessee proposes to accept the same. In this regard communication of MAP resolution dated 20.12.2024 is filed on record. Accordingly he requested for withdrawal of the appeal. The ld. DR agreed.

3.

In view of the above, the appeals of the assessee are dismissed as withdrawn.

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